Comment submitted by Ohio Utilities and Generation (OUG)

Summary: The Ohio Utilities and Generation (OUG), an association of electric utilities, supports the EPA's Legacy Amendments, particularly regarding the rescission of CCR Management Unit provisions and expanded recognition of beneficial use. However, they argue that the rules should be further modified to focus on site-specific risk assessments rather than presumed risks and to ensure that work performed under other federal or state programs is not undermined by the new rules.